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If One Borrower Leaves the Transaction, Is It HMDA Reportable?

Question: 
If a loan was originally made to two individuals and is later "refinanced," but only one of the two individuals is named as a borrower on the new obligation, is this considered the "same borrower" for purposes of determining if the loan is a HMDA-reportable refinance?
Answer: 

If one borrower leaves the transaction, such as the case in a divorce, the loan should be reported as a refinance. At least one of the original borrowers needs to carry over to the refinance.

Vendor: 

First published on 09/23/2013

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